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Case 1:20-cv-02365-LJL-DCF Document 40 Filed 08/19/21 Page 1 of 3
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
JANE DOE,
Plaintiff,
v. Case No. 1:20-cv-02365-LJL-DCF
DARREN K INDYKE and RICHARD D. KAHN, in
their capacities as executors of THE ESTATE OF
JEFFERY E. EPSTEIN,
Defendants.
JOINT PROPOSED DISCOVERY SCHEDULE
Pursuant to the Court’s Order dated July 22, 2021 (ECF No. 28) and Rule 26(f)(3) of the
Federal Rule of Civil Procedure, Plaintiff Jane Doe (“Plaintiff”) and Defendants Darren K. Indyke
and Richard D. Kahn, Co-Executors of the Estate of Jeffrey E. Epstein (together, the “Co-
Executors,” and together with Plaintiff, the “Parties”), hereby jointly submit the following
proposed discovery schedule:
1. If the Co-Executors move to dismiss Plaintiff’s Complaint in whole or in part,
Plaintiff shall have until October 6, 2021 to respond to the motion;1
2. The Co-Executors will have until October 27, 2021 to reply;
3. The Parties shall submit their initial disclosures no later than 2 weeks after the Co-
Defendants’ Answer to Plaintiff’s Complaint is filed;
4. Plaintiff shall provide HIPAA-compliant medical records release authorizations to
Defendants no later than 14 days from the request therefor;
5. The Parties shall serve initial document requests and interrogatories no later than 30
days after the Co-Defendants’ Answer to Plaintiff’s Complaint is filed;
1
Per the Court’s July 22, 2021 Order (ECF No. 28), the Co-Executors were given until September 6, 2021 to move,
answer, or otherwise respond to the Complaint.
118660810v1
Case 1:20-cv-02365-LJL-DCF
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